Sucro calls on USDA's AMS to Immediately Retract Seriously Flawed Molasses Report
After
AMS REPORT CONTAINS BASIC MATHEMATICAL ERRORS
The report's central conclusion that imported molasses entering through Buffalo allegedly fails statutory requirements at a 78% rate appears to rely on calculations that cannot be independently replicated using AMS's own published methodology.
According to a technical review of the report:
- AMS explicitly states that soluble non-sugar solids (SNSS) was calculated as:
SNSS = (Solids – Sugars) / Solids - Applying AMS's own reported Table 5 data produces materially different results than those published in Table 6.
Examples include:
- Reported solids: 74.6
- Reported sugars: 69.72
- Actual calculated SNSS: ~6.5%
- AMS reported SNSS result: 3.72%
Those numbers do not reconcile, and represent a material difference in the SNSS results. Sucro believes it is a fundamental mathematical failure at the core of the report, and calls into question the integrity of the data being presented.
AMS REPORT CONTAINS CHEMICALLY IMPOSSIBLE RESULTS
AMS also published a negative SNSS value of -4.26%. That result implies that total measured sugar exceeded total measured solids, which is chemically impossible. This was immediately flagged to AMS as an obvious red flag that should have triggered further review.
However, when informed of the impossibility over their own results, AMS claimed "it essentially means 0%." Sucro does not believe this statement supports good scientific analysis and is a retrospective rationalization of bad data.
Negative values should have triggered:
- retesting
- chain-of-custody review
- sampling review
- methodology validation
Instead, AMS simply published the data without qualification.
AMS HAS NOT PROVIDED RAW DATA
When confronted with these inconsistencies and faults, and correspondence showing repeated concerns, AMS declined to provide raw data and underlying sampling details, including;
- missing raw datasets
- unclear protocols
- inability to validate calculations
- refusal to engage transparently with stakeholders
No scientific body should publish conclusions that cannot be independently validated, and certainly not after the report has been identified to have clear, fundamental and tangible errors.
AMS WENT BEYOND ITS TECHNICAL MANDATE
Rather than staying within its scientific lane focused on product testing, AMS veered into trade policy recommendations. AMS:
- made multiple references to domestic molasses as if that was a relevant "profile". This has no bearing on verifying molasses imports under HTS 1703.10.30,
- suggested changing tariff definitions
- recommended rewriting statutory thresholds
- proposed tightening import classifications
- inserted policy recommendations well outside AMS's technical role
Sucro is disappointed that AMS made speculative, inflammatory and unsubstantiated claims that imports may involve "blending" or the use of "additives" despite providing no direct evidence proving such behavior occurred.
THE REPORT WAS PUBLICLY MARKETED BEFORE ITS ERRORS WERE ADDRESSED
Before AMS resolved obvious technical deficiencies, the report was allowed to be publicly shared with media outlets already amplifying sensationalized claims of tariff circumvention.
IMMEDIATE CORRECTIVE ACTION IS REQUIRED
AMS must:
- Immediately withdraw and officially retract publication of their report
- Provide for an independent third-party scientific review
- Ensure confidential disclosure of raw testing data with the specific importers in question
- Review AMS conduct that led to the leaking and media dissemination of a Congressionally-mandated report
- Invite Congressional oversight into how this report was commissioned and released
- Suspend any policy action based on this report
We at Sucro have showed repeated openness and willingness to be transparent and forthcoming and historically maintained a good relationship with AMS as well as all other US government entities. All we are asking is for reciprocal treatment from the government – a fair, open and honest exchange of information.
About Sucro
Sucro is a growth-oriented sugar trader and refiner that operates throughout the
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